COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report Country Chapter on the rule of law situation in Finland Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report The rule of law situation in the European Union
Date: 2022-07-13
Institutions: European Commission, Secretariat-General
Subjects: Finland, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Luxembourg, 13.7.2022  SWD(2022) 526 final  COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report         Country Chapter on the rule of law situation in Finland Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report           The rule of law situation in the European Union {COM(2022) 500 final} - {SWD(2022) 501 final} - {SWD(2022) 502 final} - {SWD(2022) 503 final} - {SWD(2022) 504 final} - {SWD(2022) 505 final} - {SWD(2022) 506 final} - {SWD(2022) 507 final} - {SWD(2022) 508 final} - {SWD(2022) 509 final} - {SWD(2022) 510 final} - {SWD(2022) 511 final} - {SWD(2022) 512 final} - {SWD(2022) 513 final} - {SWD(2022) 514 final} - {SWD(2022) 515 final} - {SWD(2022) 516 final} - {SWD(2022) 517 final} - {SWD(2022) 518 final} - {SWD(2022) 519 final} - {SWD(2022) 520 final} - {SWD(2022) 521 final} - {SWD(2022) 522 final} - {SWD(2022) 523 final} - {SWD(2022) 524 final} - {SWD(2022) 525 final} - {SWD(2022) 527 final}  
 
 
ABSTRACT 

The perceived independence of the Finnish justice system continues to be at a very high level. 
The  National  Courts  Administration  continues  to  organise  platforms  for  information 
exchanges between courts and plans to expand its activities in order to further support courts 
in  their  work.  Implementation  and  development  of  a  case  management  system  for  courts 
continues, as does the development of a reporting tool. Courts received additional funding to 
clear the backlog from the COVID-19 pandemic, but the overall level of resources and length 
of proceedings in complex cases are viewed as insufficient by stakeholders. 

Finland  continues  to  be  perceived  as  one  of  the  least  corrupt  countries  in  the  EU  and  the 
world.  A  comprehensive  National  Anti-Corruption  Strategy  and  its  Action  Plan  2021-2023 
are  currently  being  implemented.  As  part  of  the  implementation  of  the  strategy,  the  legal 
framework  to  criminalise  corruption  and  bribery  offences  is  being  reviewed,  and  a  draft 
proposal on the criminalisation of trading in influence is expected to be finalised in the first 
half of 2022. There is good cooperation between authorities in charge of the investigation and 
prosecution of corruption and the number of prosecutions of corruption-related offences has 
gone  up.  The  State  Civil  Servants’  Act  was  amended  to  strengthen  post-employment 
restrictions and asset declarations for senior management posts in the central government. A 
revision  to  limit  ‘revolving  doors’  and  prevent  conflicts  of  interests  for  Ministers  is  still 
ongoing, while the Government sent a proposal for a transparency register to the Parliament 
in June 2022. The draft legislation on whistleblower protection aimed at transposing the EU 
Directive is under preparation and should be sent to Parliament in September 2022. 

Finland  generally  offers  a  free  and  protected  environment  for  journalists  and  media 
professionals.  Media  regulatory  authorities  are  operating  independently.  The  self-regulatory 
council  has  been  dealing  with  a  rising  number  of  complaints  about  journalistic  ethics.  The 
independence  of  public  service  media  is  guaranteed  by  legislative  safeguards.  In  addition, 
there is  an unwritten practice requiring parliamentary consensus for any  legislative changes 
concerning  the  public  service  media  law.  The  Government  has  introduced  changes  in  the 
Criminal  Code  to  facilitate  the  prosecution  of  unlawful  threats  and  targeting  of  vulnerable 
victims,  such  as  freelance  journalists.  Steps  are  also  being  taken  to  reform  the  Act  on  the 
Openness of Government Activities to extend the constitutionally guaranteed right of access 
to public documents by enforcing compliance and covering more information. 

Stakeholders  are  involved  in  the  legislative  process  in  a  meaningful,  but  not  systematic 
manner. The Government continues to implement the Action Plan on Better Regulation and 
commenced works on a reform of the emergency powers act. The reform to clarify the tasks 
of  the  Chancellor  of  Justice  and  the  Ombudsman  was  adopted  by  the  Parliament.  The 
Government  works  on  a  proposal  to  establish  a  Special  Authority  Agency  of  the  Judicial 
Administration,  which  would  provide  administrative  support  to  several  independent  bodies 
providing rights protection. It has also initiated preparations of a new funding model of civil 
society organizations with a view to provide them with stable and predictable financing and 
protect their autonomy. A new Advisory Board for Civil Society Policy, which is a platform 
for the promotion of interaction between public authorities and civil society, was appointed 
by the Government. 

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RECOMMENDATIONS 

It is recommended to Finland to: 

  Continue  developing  initiatives  by  the  National  Courts  Administration  to  support  the 

work of courts. 

  Continue  to  strengthen  the  criminal  legal  framework  on  corruption,  in  particular  by  the 

adoption of legislation on trading in influence. 

  Continue efforts to implement the new National Anti-corruption Strategy and Action Plan 

2021-2023, including by starting the implementation of all planned measures. 

  Continue  the  reform  of  the  Act  on  the  Openness  of  Government  Activities  to  ensure 
effective and wider access  to  documents taking into  account the European standards on 
access to official documents. 

2 

 
 
 
I. 

JUSTICE SYSTEM  

The Finnish justice system  is  composed of the ordinary  judiciary, with  20 district  courts,  5 
courts  of  appeal  and  the  Supreme  Court,  as  well  as  the  administrative  judiciary  with  6 
regional  administrative  courts  and  the  Supreme  Administrative  Court.  There  are  three 
specialised  courts1.  The  independent  National  Courts  Administration  is  in  charge  of  the 
administration of courts, including management of budgets, buildings and ICT systems2. The 
independent Judicial Appointments Board3 prepares proposals for appointments of judges to 
the  Government,  while  proposals  for  Supreme  Court  and  Supreme  Administrative  Court 
judges are made by these courts themselves4. Judges are formally appointed by the President 
of the Republic5. The National Prosecution Authority is an independent state authority6, led 
by a Prosecutor General, who is appointed by the President on the proposal of the Ministry of 
Justice and can be dismissed or suspended by the Government7. The Finnish Bar Association8 
is  an  independent  body  tasked  with  the  supervision  of  professional  activities  of  attorneys9. 
Disciplinary  proceedings  against  lawyers10  are  conducted  by  the  Disciplinary  Board,  an 
independent  supervisory  body  functioning  alongside  the  Finnish  Bar  Association11.  Finland 
participates in the European Public Prosecutor’s Office (EPPO)12. 

Independence  

The level of perceived judicial independence in Finland continues to be very high both 
among the general public and companies. Overall, 88% of the general population and 87% 
of companies perceived the level of independence of courts and judges to be ‘fairly or very 
good’  in  202213.  According  to  data  in  the  2022  EU  Justice  Scoreboard,  the  level  remains 
consistently  very  high  for  both  the  general  public  and  companies  since  2016.  Both  figures 

1   The Market Court,  the  Labour Court and the Insurance Court.  CEPEJ (2021), Study on the functioning of 

judicial systems in the EU Member States. 

2   Courts Act, Chapter 19a, National Courts Administration. 
3   It  has  twelve  members  –  nine  judges  from  different  levels  of  courts,  proposed  by  the  judiciary,  and  three 
non-judge  members  (one  lawyer,  one  prosecutor,  one  member  representing  legal  research  and  education). 
All members are appointed by the Government for a five year term.  

4   All judges of the Supreme Court and Supreme Administrative Court participate to the selection. Courts Act, 

Chapter 11, Section 7.  

5   Only  one  candidate  is  proposed  per  vacancy.  While  the  proposal  is  non-binding,  in  practice,  it  is  almost 
always  followed,  with  only  one  exception  each  for  ordinary  court  judges  (in  2000,  the  year  the  Judicial 
Appointments Board was established) and for Supreme Court judges (in the 1970s).  

6   Act on the National Prosecution Authority (32/2019), Chapter 1, Section 2.  
7   The decision to dismiss can be appealed to the Supreme Administrative Court.  
8   Advocates Act (496/1958).  
9   There  are  three  types  of  legal  professionals  tasked  with  provision  of  different  types  of  legal  services: 

attorneys, public legal aid attorneys and licensed legal counsels.  

10   The  Disciplinary  Board  also  conducts  disciplinary  proceedings  against  two  other  types  of  legal 

professionals, public legal aid attorneys and licensed legal counsels. 

11   The Disciplinary Board is composed of a Chair and eleven Members, six of which, in addition to the Chair, 
are attorneys elected by the supreme decision-making body of the Bar Association. The remaining members, 
two of which are licenced legal counsels and three of which are lawyers, are appointed by the Government 
on the proposal of the Ministry of Justice after the Ministry has requested an opinion of the Bar Association 
on the eligibility of candidates; Sec. 7a of the Advocates Act. 

12   One  European  delegated  prosecutor  was  appointed  on  1  July  2021,  the  nomination  process  for  the  other 
European delegated prosecutors is still ongoing. Input from Finland for the 2022 Rule of Law Report, p. 17.  
13   Figures 50 and 52, 2022 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as  follows:  very  low  (below  30%  of  respondents  perceive  judicial  independence  as  fairly  good  and  very 
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

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have increased in comparison to 2021 (83% for the general public and 83% for companies). 
The  level  for  general  public  increased  also  in  comparison  to  2016,  while  the  level  for 
companies is the same as in 2016 (80% for the general public and 87% for companies). 

The National  Courts Administration continues to  facilitate information exchanges and 
intends  to  expand  its  other  activities  to  support  courts  in  their  work14.  The  National 
Courts  Administration  (NCA),  created  in  2020,  is  tasked  with  strengthening  the  structural 
autonomy and independence of the courts and reinforcing the quality of the administration of 
justice, thus allowing courts to focus on their key functions instead of administrative tasks15. 
During  the  COVID-19  pandemic,  the  NCA  started  holding  regular  meetings  with  heads  of 
courts,  which  has  developed  into  an  established  practice.  The  NCA  organises  bi-weekly 
meetings with heads of courts16, regular meetings with heads of administrations at courts, the 
Finnish Bar Association, and also runs a number of networks to discuss specific issues, such 
as ICT or data protection17, in which the courts have the opportunity to exchange information 
with  one  another  and  with  the  NCA.  The  NCA  also  intends  to  undertake  several  other 
projects,  such  as  the  improvement  of  public  statistics  related  to  courts18;  it  has  established 
cooperation  with  universities  and  research  institutions19,  but  lacks  sufficient  resources20. 
Stakeholders have expressed their appreciation for the work of the NCA, welcoming its open 
and  transparent  communication  and  noting  that  its  efforts  helped  to  establish  closer 
connections  among  courts21.  It  was  reported  that  the  NCA  respects  the  independence  of 
courts22.  

Quality  

Projects to improve the digitalisation of the justice system continue. As noted in the 2021 
Report23, the authorities have been undertaking a number of projects to further digitalise the 
justice  system.  The  biggest  among  these  is  the  development  of  two  complex  case 
management  systems,  and  the  introduction  of  a  new,  digital  working  method  they  support: 
one  system  for  administrative  courts  and  another  for  general  courts  (‘HAIPA’  and  ‘AIPA’ 
respectively),  managed  by  the  NCA.  The  HAIPA  system  was  finalised  in  202024,  and 
development still continues to improve its features. The AIPA system is being implemented 
in  phases25  and  its  roll-out  is  expected  to  continue  until  June  202326.  Some  stakeholders 

14   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 3. 
15   For more information on the establishment and structure see the 2020 Rule of Law Report, Country Chapter 
on the rule of law situation in Finland, p. 2 and the 2021 Rule of Law Report, Country Chapter on the rule of 
law situation in Finland, p. 3. 

16   Input from Finland for the 2022 Rule of Law Report, p. 17. 
17   Information received in the context of the country visit to Finland from the National Courts Administration. 
18   Input from Finland for the 2022 Rule of Law Report, p. 6. 
19   Information received in the context of the country visit to Finland from the National Courts Administration. 
20   Information received in the context of the country visit to Finland, cf. also Input from Finland for the 2022 

Rule of Law Report, p. 9. 

21   Information received in the context of the country visit to Finland from the Supreme Administrative Court, 
the Finnish Bar Association, the Supreme  Court,  the Parliamentary Ombudsman, the Chancellor of Justice 
and the Association of Judges. 

22   Information received in the context of the country visit to Finland from the Supreme Court. 
23   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 4. 
24   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 4. 
25   Civil cases are already handled by the system, but not criminal cases yet. 
26   Information received from the Ministry of Justice and the National Courts Administration. 

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welcomed  the  introduction  of  the  systems27,  while  others  noted  shortcomings,  such  as  the 
lack  of  access  by  lawyers  to  the  system28,  and  at  times  serious  technical  issues29.  The 
Ministry  of  Justice  continues  to  develop  a  reporting  tool  for  courts  and  other  authorities30, 
which  is  intended  to  increase  the  comprehensibility  of  information  and  to  produce  a  more 
detailed situational picture31. The development of the tool is expected to be finalised by the 
end of 202232. 

The authorities continue to explore possibilities of making justice more accessible33. The 
costs of judicial proceedings are considered to be high, which may hinder access to justice34. 
In this context,  the Ministry of Justice initiated a research project  in  June 2020 to  examine 
access to legal aid35, which resulted in a publication of a study in October 2021, concluding 
that  free  legal  aid  is  not  available  to  all  people  with  low  incomes36.  The  Government  has 
reflected  on  the  possibility  of  making  changes  to  the  system37,  and  progressed  with  the 
initiative to create a central National Legal Aid and Guardianship Authority38 to centralise the 
administration of legal aid39 and a draft act was prepared by the Ministry of Justice. However, 
the  further  action  of  implementation  has  been  postponed  until  further  notice40.  It  is  also 
examining  the  possibilities  to  reform  the  legislation  on  legal  costs  in  civil  cases41  and  to 
create  a  special  court  procedure  for  small  claims  civil  cases42.  Stakeholders  welcomed  the 
initiatives43, but noted that the issue of costs of proceedings, which is closely connected also 
to the length of proceedings, will require a more complex solution44. 

The  courts  received  special  funding  to  clear  the  backlog  caused  by  the  COVID-19 
pandemic,  but  there  are  questions  about  the  level  of  resources.  In  2021,  the  courts 

27   Information received in the context of the country visit to Finland from the Supreme Administrative Court, 

the Supreme Court and the Chancellor of Justice. 

28   Contribution from the Finnish Bar Association for the 2022 Rule of Law Report p. 14. 
29   Contribution from the European Association of Judges for the 2022 Rule of Law Report, p. 30.See also 2021 

Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 4. 

30   Input from Finland for the 2022 Rule of Law Report, p. 8. 
31   Information received in the context of the country visit to Finland from the Ministry of Justice. 
32   Information received in the context of the country visit to Finland from the Ministry of Justice. 
33   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 5. 
34   Contribution from the Finnish Bar Association for the 2022 Rule of Law Report p. 12; Contribution from the 
National  Human  Rights  Center  for  the  2022  Rule  of  Law  Report,  p.  12;  Contribution  from  Demla  for  the 
2022  Rule  of  Law  Report,  p.  11;  Contribution  from  the  Chancellor  of  Justice  for  the  2022  Rule  of  Law 
Report p. 2. 

35   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 5. 
36   Input from Finland for the 2022 Rule of Law Report, p. 8. 
37   Input from Finland for the 2022 Rule of Law Report, p. 8; information received in the context of the country 

visit to Finland from the Ministry of Justice. 

38   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 5. 
39   Legal  aid  is  provided  by  public  legal  aid  attorneys  in  Legal  aid  offices,  however  due  to  limited  resources 
some  cases  are  assigned  to  other  lawyers  (attorneys  and  licensed  legal  counsels,  cf.  2021  Rule  of  Law 
Report, Country Chapter on the rule of law situation in Finland, footnote 9) for fees that are reportedly very 
low, which leads to further problems with access to legal aid; Contribution from the Finnish Bar Association 
for the 2022 Rule of Law Report p. 12.  

40   Input from Finland for the 2022 Rule of Law Report, p. 8. 
41   A working group prepared a proposal in May 2022, which was then sent for public consultation; input from 

Finland for the 2022 Rule of Law Report, p. 8.  

42   The Ministry of Justice is currently preparing an assessment memorandum; input from Finland for the 2022 

Rule of Law Report, p. 8. 

43   Information received in the context of the country visit to Finland from the Chancellor of Justice. 
44   Contribution from the Chancellor of Justice for the 2022 Rule of Law Report pp. 2-3. 

5 

 
                                                 
received additional funding (EUR 14 million, which corresponds to approximately 5 % of the 
budget for courts45) to help alleviate the backlog created during the COVID-19 pandemic46. 
The  extra  funding  was  welcomed  by  the  stakeholders,  but  its  effect  was  not  immediate,  as 
recruiting  new  judges  for  temporary  posts  supported  by  this  funding  took  time47. 
Stakeholders  however  reported  that  an  overall  lack  of  financial  resources,  judges  and  court 
staff remains an important issue48. In 2020, the total expenditure on courts was 0.24 % GDP, 
which  is  low  according  to  the  information  contained  in  the  EU  Justice  Scoreboard49.  The 
Ministry of Justice is currently preparing a report on the operational conditions, including the 
state  of  resources  of  courts  and  of  other  state  authorities.  The  report  is  expected  to  be 
submitted to the Parliament in autumn 202250. 

Efficiency 

The  justice  system  continues  to  perform  efficiently,  but  efficiency  decreased  in  2020, 
and length of proceedings in complex cases is considered as problematic. The clearance 
rate  for  litigious  civil  and  commercial  cases  has  decreased  from  100  %  in  2019  to  94%  in 
202051, while the clearance rate for administrative cases has slightly decreased from 100% in 
2019 to 99% in 202052. The number of pending cases per 100 inhabitants, however, continues 
to  be  low  for  civil  and  commercial  cases  and  average  for  administrative  cases53.  The 
estimated  time  to  resolve  litigious  civil  and  commercial  cases  is  average54.  However, 
stakeholders note that while there are efficient processes to expediently resolve certain types 
of cases such as small claims or undisputed criminal matters55, the length of proceedings is 
problematic especially in more complex cases56. 

II. 

ANTI-CORRUPTION FRAMEWORK  

In  Finland,  several  authorities  work  alongside  the  Police,  the  National  Bureau  of 
Investigation and the Prosecution Service to monitor, detect and prevent cases of corruption. 
These authorities include the Financial Intelligence Unit (FIU)57, the National Audit Office of 
Finland  (NAOF),  the  Finnish  Competition  and  Consumer  Authority  (FCCA)  as  well  as  the 
Parliamentary  Ombudsman58  and  Chancellor  of  Justice59.  The  Ministry  of  Justice’s 
Department  of  Criminal  Policy  and  Criminal  Law  continues  supervising  anti-corruption 

45   Excluding the Supreme Court and the Supreme Administrative Court, which have separate budgets. 
46   Input from Finland for the 2022 Rule of Law Report,  p. 8; information received from the National Courts 

Administration. 

47   Information received in the context of the country visit to Finland from the National Courts Administration. 
48   Contribution from the Finnish Bar Association for the 2022 Rule of Law Report p. 13, Contribution from the 
National  Human  Rights  Center  for  the  2022  Rule  of  Law  Report,  p.  12;  Contribution  from  the  European 
Association of Judges for the 2022 Rule of Law Report, pp. 2, 24, 34. 

49   Figure 35, 2022 EU Justice Scoreboard. 
50   Input from Finland for the 2022 Rule of Law Report, p. 16. 
51   Figure 12, 2022 EU Justice Scoreboard.  
52   Figure 13, 2022 EU Justice Scoreboard.  
53   Figures 15-16, 2022 EU Justice Scoreboard.  
54   In 2020, the estimate  time  was 300 days for first instance courts, 210 days for second  instance courts and 

127 days for third instance courts. Figure 8, 2022 EU Justice Scoreboard. 

55   Information received in the context of the country visit to Finland from the National Courts Administration.  
56   Contribution from the Chancellor of Justice for the 2022 Rule of Law Report pp. 4-5; Contribution from the 

Finnish Bar Association for the 2022 Rule of Law Report p. 15. 

57   The Financial Intelligence Unit: https://poliisi.fi/en/money-laundering. 
58   The Parliamentary Ombudsman of Finland: https://www.oikeusasiamies.fi/en. 
59   The Chancellor of Justice: https://www.okv.fi/en/. 

6 

 
                                                 
efforts  and  coordinating  the  anti-corruption  network  involving  representatives  of  several 
ministries, police, trade unions and civil society60.  

The perception among experts and business executives is that Finland is one of the least 
corrupt countries in the world. In the 2021 Corruption Perceptions Index by Transparency 
International, Finland scores 88/100 and ranks 1st in the European Union and globally61. This 
perception  has  been  relatively  stable  over  the  past  five  years62.  The  2022  Special 
Eurobarometer on Corruption shows that 17% of respondents consider corruption widespread 
in  their  country  (EU  average  68%)  and  10%  of  respondents  feel  personally  affected  by 
corruption in their daily lives (EU average 24%)63. As regards businesses, 24% of companies 
consider  that  corruption  is  widespread  (EU  average  63%)  and  15%  consider  that  that 
corruption  is  a  problem  when  doing  business  (EU  average  34%)64.  Furthermore,  46%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 
practices  (EU  average  34%)65,  while  48%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 29%)66. 

The implementation of the National Anti-Corruption Strategy and its 2021-2023 Action 
Plan has started and is showing progress. As noted in the 2021 Rule of Law Report, a first 
National Anti-Corruption Strategy was adopted in May 202167. The strategy includes a time-
limited  Action  Plan  with  clear  and  measurable  objectives  that  expands  on  six  development 
areas for combating and preventing corruption68. Progress in meeting the relevant measures 
of the Action Plan is overseen by the preparation and steering group led by the Ministry of 
Justice,  which  reports  to  the  Ministerial  Working  Group  on  Internal  Security  and 
Strengthening the Rule of Law69. The latest assessment of the steering group concluded that 
since June 2022, 65 of the 79 planned measures started to be implemented, out of which nine 
actions have already been completed and 22 actions are well advanced70. 

60   Anti-corruption.fi website https://korruptiontorjunta.fi/en/combating-corruption-in-finland#network. 
61   Transparency  International  (2022),  Corruption  Perceptions  Index  2021,  pp.  2-3.  The  level  of  perceived 
corruption  is  categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public 
sector  corruption scores  above  79);  relatively  low  (scores  between  79-60),  relatively  high  (scores  between 
59-50), high (scores below 50). 

62   In 2017 the score was 85, while, in 2021, the score is 88. The score significantly increases/decreases when it 
changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively  stable 
(changes from 1-3 points) in the last five years. 

63   Special  Eurobarometer  523  (2022).  The  Eurobarometer  data  on  citizens’  corruption  perception  and 
experience is updated every second year. The previous data set is the Special Eurobarometer 502 (2020). 
64   Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022). The Eurobarometer 
data on business attitudes towards corruption as is updated every second year. The previous data set is the 
Flash Eurobarometer 482 (2019). 

65   Special Eurobarometer 523 on Corruption (2022). 
66   Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022). 
67   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7. 
68   These areas are: the cooperation between anti-corruption bodies, awareness raising, increased transparency 
and  exposure  of  corruption,  development  of  anti-corruption  legislation  and  promotion  of  research  on 
corruption and its prevention. Government Resolution on the National Anti-Corruption Strategy and Action 
Plan 2021-2023, p.10.  

69   Government Resolution on the National Anti-Corruption Strategy and Action Plan 2021-2023. 
70   National  Anti-Corruption  Action  Plan  2021-2023  -  The  assessment  of  the  implementation  by  24.2.2022- 
Input  from  Finland  for  the  2022  Rule  of  Law  Report,  p.  18  and  its  attachments  1  and  3  and  written 
information received from Finnish authorities in the context of the country visit to Finland. 

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The Ministry of Justice has started work on the criminalisation of trading in influence. 
While  the  Finnish  legal  framework  criminalises  corruption  and  bribery  offences,  trading  in 
influence remains unregulated71. Previous attempts to criminalise trading in influence led to 
long  discussions  in  Parliament  without  any  result72.  The  Ministry  of  Justice  is  currently 
preparing  a  legislative  proposal  on  trading  in  influence73,  which  is  expected  to  be  finalised 
before the summer74 and submitted to public consultation by the end of 202275. The Ministry 
of  Justice  is  also  planning  to  analyse  whether  the  Criminal  Code  provisions  on  bribery 
offences  in  public  office  are  up-to-date  or  in  need  of  further  reforms76.  The  Ministry  of 
Justice  is  still  looking  into  the  possibility  of  extending  the  liability  of  offences  in  office  to 
cover municipal and state majority-owned companies77.  

There  continues  to  be  good  cooperation  between  authorities  in  charge  of  the 
investigation  and  prosecution  of  corruption,  although  there  are  no  specialised  anti-
corruption units within the police and prosecutor’s office. In Finland, corruption related 
crimes  are  investigated  and  prosecuted  following  the  same  procedures  and  safeguards  as 
other types of criminal offences. Supporting the investigations of complex corruption by the 
National Bureau of Investigation (NBI)78, the FIU receives and analyses reports of suspicious 
transactions linked to corruption and other financial crimes and delivers an assessment to the 
relevant  authorities79.  When  the  FIU  identifies  suspected  high-level  corruption,  the 
investigation  is  transferred  to  the  NBI80.  Within  the  police,  resources  remain  adequate  to 
handle  economic  crime  investigations,  including  corruption  and  bribery81.  While  police 
investigations  are  subjected  to  their  own  process  and  administration82,  they  cooperate  and 
share information with the National Prosecution Authority at the national and regional levels, 
which  continues  to  work  well83.  The  preliminary  investigative  Act  on  the  National 
Prosecution Authority sets  good grounds for this  cooperation, and assigns to  the prosecutor 
the authority to bring charges to a district court after a completed investigation84.  

71   GRECO Fifth Evaluation Round - Evaluation Report, para 12, p. 7. 
72   2020 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 5. 
73   Target  5.1.1  Assessment  of  criminalisation  and  necessary  amendments,  Government  Resolution  on  the 

National Anti-Corruption Strategy and Action Plan 2021-2023, p. 42. 

74   Information received from Ministry of Justice in the context of the country visit to Finland. 
75   As reported by authorities in the latest assessment of the implementation.  Input from  Finland for the 2022 

Rule of Law Report, p. 25. 

76   Input  from  Finland  for  the  2022  Rule  of  Law  Report,  p.  25.  Chapter  30  of  the  Criminal  Code  of  Finland 
(39/1889),  business  offences;  2020  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in 
Finland, p. 5. 

77   Target  4.3.22  Examine  the  possibility  of  extending  liability  for  acts  in  office  to  cover municipal  and  state 
majority-owned companies in Government Resolution on the National Anti-Corruption Strategy and Action 
Plan 2021-2023, p. 41. This exercise was supposed to be carried out in 2020 and 2021. 

78   The  National  Bureau  of  Investigation  continues  developing  methods  for  detecting  and  investigating 
corruption  and  oversees  the  investigation  of  high-level  corruption,  which  often  requires  more  complex 
processes.  Information  received  from  NBI  and  national  prosecutor  in  the  context  of  the  country  visit  to 
Finland. 

79   The Financial Intelligence Unit: https://poliisi.fi/en/money-laundering. 
80   Information received from NBI in the context of the country visit to Finland. 
81   Information  received  from  NBI  and  national  prosecutor  in  the  context  of  the  country  visit  to  Finland:  the 
number  of  police  investigations  of  economic  criminal  offences,  including  corruption,  amounted  to  400  in 
2021 and 87 cases where investigated by the NBI.  

82   Act on Police Administration. 
83   Information received from NBI and National Prosecutor in the context of the country visit to Finland; 2021 

Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 6. 

84   Ministry of Justice. Act on the National Prosecution Authority (32/2019). 

8 

 
                                                 
The number of prosecutions of corruption-related offences has gone up. As reported last 
year,85  there  are  six  prosecutors  specialised  in  corruption  offences  and  19  specialised  in 
prosecuting  offences  committed  in  office.  There  are  also  specialised  financial  crime 
prosecutors who often handle bribery offences in all prosecution districts86. During 2021 the 
number of corruption and bribery cases reported to the police increased87. This is mainly due 
to a high-profile case involving several high-level officials of the National Audit Office, who 
were  found  guilty  of  fraud  and  misconduct  in  public  office88.  This  case  required  extra 
resources,  provided  by  the  allocation  of  temporary  resources  to  support  the  prosecution  of 
complex  cases89.  In  2021,  the  prosecution  service  received  90  corruption  cases  from  the 
police. During that  year, the prosecution service  decided on 68 cases, out of which charges 
were  brought  in  56  cases,  and  19  cases  were  dismissed90.  This  represents  an  exponential 
increase  from  the  average  of  ten  cases  that  are  prosecuted  per  year,  as  reported  last  year91. 
While convictions for corruption offences are quite limited in Finnish criminal courts92, the 
increase of prosecutions may change this in the near future. 

A  political  decision  continues  to  be  required  for  the  investigation  and  prosecution  of 
important  categories  of  high-level  corruption.  As  reported  last  year,  investigations  of 
corruption  by  members  of  the  Government  follow  a  different  procedure  than  normal 
corruption  investigations93.  It  is  for  a  Parliamentary  Committee  to  bring  Members  of  the 
Government suspected of unlawful conduct in office, including corruption, to the High Court 
of Impeachment94. Only then, the Member of the Government can be held accountable in the 
high-level court. As noted by GRECO, depriving the prosecutor in charge of the case of the 
power to request the opening of an inquiry could be an obstacle to the proper functioning of 
the  criminal  justice  system.  The  special  process  provides  the  minister  with  notice  of  a 
potential criminal investigation and raises the risk of losing evidence and losing track of the 
criminal  assets  during  this  procedural  stage.  Besides,  a  Parliamentary  Committee,  by 
definition a political body, could be influenced in its work by political considerations95.  

Government  efforts  to  enhance  detection  and  exposure  of  foreign  bribery  continue. 
Since 2021, trainings for criminal investigators, prosecutors and judges on the application of 
foreign bribery offences have been conducted96. The Government published in February 2022 
a comprehensive study on corruption in international business, including foreign bribery97. A 

85   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 6. 
86  The  National  Prosecution  Authority.  Prosecution  districts,  https://syyttajalaitos.fi/en/prosecution-

districts;2020 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 6. 

87   Input from Finland for the 2022 Rule of Law Report; Information received from National Prosecutor in the 

context of the country visit to Finland. 

88   See Yle (2022), ‘National Audit Office dismisses as Director General’. 
89   Information received from national prosecutor in the context of the country visit to Finland. 
90   Information received from national prosecutor in the context of the country visit to Finland.   
91   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 5. 
92   According  to  the  2009-2020  legal  statistics,  only  individuals  have  been  convicted  in  county  courts  for 
corruption  offences.  Corruption  in  international  business,  Current  state  of  regulation,  application  practice 
and training and needs for change, p. 18 (Government Office, Helsinki 2022). 

93   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7. 
94   The Constitution of Finland, 11 June 1999, including amendments up to 817/2018, Chapter 10, Section 114; 
https://www.finlex.fi/en/laki/kaannokset/1999/en19990731.pdf;  Input  from  Finland  for  the  2021  Rule  of 
Law Report, p. 20.  

95   GRECO Fifth Evaluation Round – Compliance Report, para. 39-41. 
96   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7. 
97   Corruption in international business, Current state of regulation, application practice and training and needs 

for change (Government Office, Helsinki 2022). 

9 

 
                                                 
set of recommendations was also prepared on law enforcement, evidence issues, liability of 
legal  persons  and  training98.  In  particular,  the  study  calls  for  legislative  amendments  on 
bribery and to align the law with international standards. The study also emphasises the need 
to  develop  further  training  and  more  support  on  evidence  requirements  in  connection  to 
bribery offences to enhance enforcement.  

The  State  Civil Servants’  Act  was  amended  to  strengthen  asset  declarations  and post-
employment  rules.  As  reported  last  year99,  rules  on  ethics  and  conflicts  of  interests  in  the 
public administration have been harmonised for civil servants and persons entrusted with top 
executive functions, excluding Ministers100.  In addition, a Government proposal101 has been 
issued  to  amend  rules  on  recruitment102,  post-employment  restrictions103  and  declaration  of 
interests  provided  in  the  State  Civil  Servants’  Act.  The  proposal  was  submitted  to  the 
Parliament  in  autumn  2021104  and  adopted  in  May  2022.  As  reported  last  year105,  one 
amendment introduces a cooling-off period of 12 months for civil servants occupying senior 
management posts in the central government106. Another amendment concerns the regime for 
declarations  of  interests  by  persons  holding  top  executive  functions  in  the  central 
government,  including  special  advisers  of  ministers107.  The  aim  is  to  lay  down  uniform 
requirements as to the information, which must be included in the declarations. Entering into 
force  in  June  2022,  this  reform  is  in  line  with  GRECO  recommendations  on  the  need  to 
ensure that declarations are accurate, standardised and timely108.  

Work  on  the  transparency  register,  launched  in  2020,  is  progressing,  while  lobbying 
remains  unregulated.  In  December  2021,  the  parliamentary  steering  group  and  the  expert 
working group submitted a report for a transparency register act to the Ministry of Justice109. 
While lobbying remains unregulated110, the proposed Transparency Register Act will oblige 
those engaged in influencing activities to register in the electronic transparency register and 
to report their activities by means of a biannual activity report111. The objective of the register 
is  to  provide citizens  and the targets  of lobbying a more comprehensive  overview of actors 
influencing decision-makers at the state level112. The current proposal is being drafted and is 

98   Corruption in international business, Current state of regulation, application practice and training and needs 

for change, pp. 236-246 (Government Office, Helsinki 2022).  

99   2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 7. 
100  Finnish Government (2021), Code of conduct for officials (Virkamieseettinen toimintaohje).  
101  Government  proposal  HE  187/2021  vp  for  a  law  amending  the  State  Civil  Servants’  Act  (Act  on  Public 

Officials in Central Government).  

102  Article 6b of the State Civil Servants’ Act. 
103 Article 44a of the State Civil Servants’ Act. 
104  Input from Finland for the 2022 Rule of Law Report, p. 19. 
105  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 8. 
106  Article 44a of the State Civil Servants’ Act. 
107  Article  8a  of  the  State  Civil  Servants’  Act.  The  amendment  also  aims  to  extend  the  special  advisers  of 
ministers  to  the  scope  of  Article  8a  of  the  State  Civil  Servants’  Act  in  accordance  with  GRECO's 
recommendation for action. 

108  GRECO Fifth Evaluation Round – Compliance Report, recommendation v, paras 32-34.  
109  Transparency  register  legislation:  Report  of  the  Parliamentary  Steering  Group  and  the  Expert  Working 

Group. 

110  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 8. 
111  Transparency  register  legislation:  Report  of  the  Parliamentary  Steering  Group  and  the  Expert  Working 

Group. 

112  Transparency  register  legislation:  Report  of  the  Parliamentary  Steering  Group  and  the  Expert  Working 

Group. 

10 

 
                                                 
to be subject to consultation from 27 June to 22 August 2022, before being sent to Parliament 
in the autumn of 2022113.  

A  legislative  proposal  on  limiting  ‘revolving  doors’  for  Ministers  is  still  under 
preparation.  As  reported  in  previous  years114,  there  is  an  ongoing  legislative  project  to 
regulate  procedures  for  preventing  conflicts  of  interest  when  a  Member  of  the  Government 
changes positions. Ministers are not  subject  to  the  ‘revolving door’  restrictions  of the  State 
Civil  Servants’  Act,  instead  they  follow  the  Advisory  Board  for  Civil  Service  Ethics 
recommendation  to  inform  about  their  intention  to  take  upon  new  duties  after  their 
appointment as ministers115. The proposal was planned to be submitted to the Parliament in 
spring 2021 but has been postponed to the second half of 2022116. 

A legislative proposal to amend the legislation on political parties and electoral funding 
is still under preparation. The parliamentary electoral working group composed in 2020117 
issued a report in February 2022 examining the need to amend the electoral, party and party 
funding legislation118. The report proposes several amendments to the Act on a Candidate’s 
Election  Funding,  including  clarifying  the  funding  that  exceeds  campaign  costs  and 
strengthening  supervisory  powers  related  to  post  election  disclosures119.  The  report  also 
suggested  to  strengthen  the  supervisory  work  of  the  National  Audit  Office,  in  charge  of 
overseeing  political  party  financing120,  by  allowing  it  to  impose  conditional  fines121.  The 
current proposal is being drafted and is to be subject to consultation in summer 2022 before 
being sent to Parliament in the autumn of 2022122. 

A  draft  bill  on  protection  of  whistleblowers  should  be  sent  to  the  Parliament  in 
September 2022. The draft law aims at transposing the EU Whistleblowing Directive123 and 
extending protection to persons reporting corruption and economic related crimes124. The law 
was  expected  to  enter  into  force  in  December  2021125,  but  its  intended  submission  to  the 
Parliament was postponed to September 2022126. Finland does not currently have a dedicated 
whistleblower protection office and the draft law envisages that reports coming from external 
individuals should be received by the Chancellor of Justice’s Office, which will forward the 
report  to  the  assigned  investigative  units127.  The  working  group  to  prepare  a  technical 

113 Written information received from Finnish authorities in the context of the country visit to Finland. 

Information about the legislative process https://oikeusministerio.fi/hanke?tunnus=OM033:00/2019. 

114  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 8. 
115  2020 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 8. 
116  Information received from the Prime Minister’s Office in the context of the country visit to Finland. 
117  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 8. 
118  This  legislation  includes:  Election  Act,  the  Act  on  Political  Parties,  the  Act  on  a  Candidate’s  Election 
Funding and, if necessary, any other legislation regarding political activities; Input from Finland for the 2022 
Rule of Law Report, p. 21.  

119  Parliamentary election working group (2022) Final report.  
120 The National Audit Office's report to Parliament on the oversight of the funding of political parties in 2021 

was published on 23 February 2022. 

121  The  possibility of introducing a campaign account in connection  with parliamentary elections, elections to 
the  European  Parliament  and  presidential  elections  could  be  examined.  Final  report  of  the  parliamentary 
electoral working group provided by the Finnish authorities 
122  Input from Finland for the 2022 Rule of Law Report, p. 21. 
123 Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.  
124  Written information received from Finnish authorities in the context of the country visit to Finland. 
125  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10. 
126  Input from Finland for the 2022 Rule of Law Report, p. 22. 
127  Written information received from Finnish authorities in the context of the country visit to Finland. 

11 

 
                                                 
 
whistleblowing  channel  service  for  irregularities  in  the  central  government  including 
government  agencies,  set  up  in  line  with  the  implementation  of  the  EU  Whistleblowing 
Directive by the Ministry of Finance in March 2021128, published its final report in July 2021. 
Since  then,  the  State  Treasury  has  continued  the  work  to  introduce  the  technical 
whistleblowing channel service129. 

While  corruption  has  not  been  identified  as  an  increased  risk  during  the  COVID-19 
pandemic,  a  government  initiative  is  seeking  to  reinforce  transparency  of  decision-
making  in  the  management  of  the  pandemic.  The  Chancellor  of  Justice  called  on  the 
Ministry of Social Affairs and Health to improve the transparency of decision-making on the 
management of the epidemic130. In April 2022, the Ministry replied that relevant statements 
and memorandums that related directly to the decision-making have been published as soon 
as their publication was possible, and that the government's proposals and decrees have been 
prepared in accordance with the relevant government's guidelines131.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

In Finland, freedom of expression is protected by the Constitution, guaranteeing also the right 
of  access  to  public  documents.  Finland  requires  media  service  providers  to  make  publicly 
accessible  information  concerning  their  ownership  structure.  The  tasks  and  powers  of  the 
Finnish Transport and Communications Agency (Traficom), the media regulatory authority, 
are  ensured  by  law,  as  are  the  mandate  and  monitoring  of  the  public  service  media132. 
Legislation  has  been  adopted  to  transpose  the  revised  Audiovisual  Media  Services 
Directive133. 

The  media  regulatory  authority  Traficom  has  been  subject  to  pre-planned  staff 
reductions134.  However,  the  authority  considers  the  overall  impact  limited  and  reports  no 
new  risk  concerning  a  further  reduction  of  resources135.  In  turn,  the  National  Audiovisual 
Institute, another independent media body with more specialist functions136, reports that their 
resources have remained stable, but they have been operating with a limited budget for a long 

128  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 10. 
129  Written information received from Finnish authorities in the context of the country visit to Finland. 
130  Chancellor of Justice (2022), Press statement, Chancellor of Justice Tuomas Pöysti: Improving transparency 
in  decision-making  regarding  the  management  of  the  coronavirus  epidemic;  Written  contribution  from  the 
Chancellor of Justice in the context of the country visit to Finland, pp. 15-16. 
131  Written contribution received from Finland in the context of the country visit. 
132  Act on Yleisradio Oy (Laki Yleisradio Oy:stä) 1380/1993. 
133  Directive  (EU)  2018/1808  amending  Directive  2010/13/EU  on  the  coordination  of  certain  provisions  laid 
down by law, regulation or administrative action in Member States concerning the provision of audiovisual 
media services (Audiovisual Media Services Directive) in view of changing market realities.  Finland ranks 
2nd  in  the  2022  Reporters  without  Borders  World  Press  Freedom  Index  compared  to  5th  in  the  previous 
year. 

134  As announced in the 2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 

10. 

135  Information received from Traficom in the context of the country visit. 
136  Besides  classifying  audiovisual  programmes  for  the  purpose  of  the  protection  of  minors,  the  National    
Audiovisual  Institute  has  a  statutory  duty  (the  Act  on  the  National  Audiovisual  Institute  1434/2007)  to 
promote media education. 

12 

 
                                                 
period  of  time137.  No  developments  have  been  reported  regarding  the  authorities’ 
independence, which the MPM 2022 considers to continue to carry a low risk138. 

The  number  of  complaints  filed  at  the  Finnish  Council  for  Mass  Media  has  risen 
significantly. The self-regulatory council reports that complaints about journalistic ethics are 
rising considerably for two years in a row. The body attributes this to increased awareness of 
and  trust  in  the  complaint  mechanism  among  citizens,  coupled  with  a  rise  in  COVID-19 
related  complaints.  The  Council  has  anyway  managed  to  reduce  the  length  of  complaint 
handling procedure due to state funding and reallocation of funds, which were made possible 
by savings brought about by general travel restrictions affecting the Council’s staff caused by 
the pandemic139. 

In Finland, there are no specific rules regulating the fairness and transparency of state 
advertising.  When  the  state  purchases  advertisement  space  exceeding  pre-determined 
threshold  values,  the  public  procurement  procedures140  apply.  The  principles  of  non-
discrimination,  equality,  transparency  and  proportionality  form  the  foundations  for  the 
procurement obligations. Consideration may also be given to adequate transparency and non-
discrimination for purchases under the threshold values, having regard to the size and scope 
the  state  purchases  advertisements  or  other  public 
of 
communications,  this  activity  falls  within  the  scope  of  public  administration,  where  the 
Administrative  Procedure  Act142  and  the  legal  principles  of  good  administration  apply143. 
Stakeholders  do  not  consider  the  fairness  of  state  advertising  to  be  an  issue  because  the 
amounts  allocated  are  generally  rather  small  but  information  in  this  field  is  only  available 
upon specific request144. 

the  procurement141.  When 

Restrictions for media ownership and concentration are limited. Privately owned digital 
television  broadcasters  and  digital  and  analogue  radio  companies  must  obtain  a  licence  to 
operate.  The  detailed  procedures  for  operating  licenses  are  provided  for  in  the  Act  on 
Electronic  Communications  Services145.  If  there  is  not  enough  technical  capacity  or  the 
granting  of  the  licence  could  have  a  significant  effect  on  the  communications  market,  the 
decision  to  grant  a  licence  is  made  by  the  Government  instead  of  Traficom,  based  on 
considerations of the overall market situation. There are no quantitative rules for market entry 
or operation. News media concentration in Finland is very high146.  

The  independence  of  public  service  media  is  regularly  monitored  and  subject  to 
safeguards.  The  members  of  the  Administrative  Council  of  Yleisradio  Oy  (The  Finnish 
Broadcasting Company – Yle) are elected by the Parliament in its first session of the electoral 
term  for  a  four-year  mandate.  Their  term  of  office  begins  as  soon  as  the  election  has  been 

137  Information received from the National Audiovisual Institute in the context of the country visit. 
138  2022 Media Pluralism Monitor, country report for Finland, p. 10. 
139  Information received from the Finnish Council for Mass Media in the context of the country visit; ‘Number 
of complaints rose and processing accelerated in 2021’,  https://www.jsn.fi/uutiset/kanteluiden-maara-nousi-
ja-kasittely-nopeutui-vuonna-2021/. 

140  Act on Public Procurement and Concession Contracts 1397/2016. 
141  Input from Finland for the 2022 Rule of Law Report, p. 27. 
142  Administrative Procedure Act 434/2003. 
143  Input from Finland for the 2022 Rule of Law Report, p. 27. 
144  Information  received  from  The  Finnish  Media  Federation  (Finnmedia)  and  the  Union  of  Journalists  in 

Finland in the context of the 2022 country visit to Finland. 

145  Act on Electronic Communications Services 917/2014. 
146  2022 Media Pluralism Monitor, country report for Finland, p. 13. 

13 

 
                                                 
completed and continues until new members of the Administrative Council are elected. The 
members consist of incumbent MPs in equal proportion to the seats in the Parliament which 
must have expertise in the fields of science, art, education, business and economics, as well 
as  representatives  of  different  social  and  language  groups.  The  MPM  2022  notes  that 
although the public service media is under indirect political control, politicians’ attempts to 
influence  it  are  rare147.  The  members  of  the  Administrative  Council  choose  annually  for  a 
one-year mandate the Board of Directors, which is composed of external experts and which, 
elects,  among  others,  the  company’s  management  and  answers  for  the  productivity  of  the 
operations. The public service media reports on its activities annually to the Parliament and 
Traficom,  conducts  an external  audit on its independence148 and holds monthly meetings to 
discuss  possible  sources  of  undue  influence149.  In  Finland,  the  long-standing  unwritten 
practice is  to  require a  consensus  of all parties in  the Parliament  for any  political  decisions 
concerning  the  law  governing  the  public  service  media150.  The  public  service  media’s 
provision  of  text-based  services,  which  was  not  previously  defined  in  law,  has  generated 
complaints  among  certain  stakeholders  concerning  the  public  service  media  possibly 
overstepping its remit, and has led to a recent reform of the legislation requiring the online 
text content published by the public service media to be more closely linked to its audio  or 
video content151. 

Preparations to reform the Act on the Openness of Government Activities continue. The 
working group appointed by the Ministry of Justice has not yet presented any proposal for an 
urgent  change  of  the  legislation152,  but  preparations  for  the  reform  to  extend  the 
constitutionally guaranteed right of access to public documents by enforcing compliance and 
covering  more  information  are  ongoing  and  stakeholders  have  been  actively  involved153. 
There  have  been  a  few  court  cases  regarding  access  to  public  documents,  including  the 
withholding  of  COVID-19-related  documents  from  the  media154,  which  have  resulted  in 
access  rights  being  eventually  given.  In  2021,  the  Supreme  Administrative  Court  delivered 
two  judgments  concerning  access  to  public  documents,  which  clarify  that  with  regard  to 
information  held  by  the  police  in  specific  criminal  cases,  several  exceptions  of  the  Act  on 
Openness  of  Government  Activities  may  be  applied  simultaneously155.  The  MPM  2022 
identifies  a  medium  risk  score  concerning  the  protection  of  right  to  information  due  to 

147  2022 Media Pluralism Monitor, country report for Finland, p. 23. 
148  See Yleisradio Oy’s annual reports here: https://yle.fi/aihe/about-yle/annual-reports.  
149  Information received from Yleisradio Oy in the context of the country visit. 
150  Ibid; Kari Eerik Karppinen (2017), Finland: Maintaining the fragile consensus. 
151  Input from Oikeuspoliittinen yhdistys Demla ry – Legal Policy Association in Finland for the 2022 Rule of 

Law Report; Input from Finland for the 2022 Rule of Law Report, p. 31; Sanoma (2021); Act  
amending Section 7 of the Act on Yleisradio Oy (Laki Yleisradio Oy:stä annetun lain 7 §:n muuttamisesta) 
159/2022. 

152  As reported in the 2021 Rule of Law Report, the Working Group was appointed to assess the need to revise 
and  modernise  the  current  law,  including  the  sufficiency  of  its  scope  and  possible  shortcomings  and  to 
provide solutions. 

153  Information  received  from  the  Ministry  of  Justice,  the  Finnish  Media  Association,  the  Union  of  Finnish 

Journalists and the Finnish Council for Mass Media in the context of the country visit. 

154  Helsingin  Sanomat  (2022),  ‘The  Prime  Minister's  Office's  decision  to  withhold  documents  from  the 

coronavirus coordination group violated the law’. 

155  Supreme  Administrative  Court, 

judgment  of  26  February  2021,  5198/1/19,  KHO:2021:26, 

ECLI:FI:KHO:2021:26;  
Supreme  Administrative  Court, 
ECLI:FI:KHO:2021:170. 

judgment  of  1  December  2021,  20208/2021,  KHO:2021:170, 

14 

 
                                                 
instances where access  to  documents and information  held  by officials  has been delayed or 
denied because of either misinformed or wilfully unlawful practice156. 

Protection  of  journalists  from  threats  has  been  strengthened.  The  Criminal  Code 
amendment, which was being prepared in 2021157, has entered into force in October 2021158. 
It allows public prosecutors in certain cases to bring charges on the victim’s behalf for threats 
where the victim has a justified reason to believe that their personal safety or property or that 
of someone else is in serious danger. This amendment has been welcomed by stakeholders, as 
it  also  covers  threats  against  journalists  and  other  vulnerable  victims  including  freelance 
journalists, and can step-up intervention in online shaming and other threats159. A few months 
after the adoption of the amendment, the Supreme Court delivered a high-profile judgment160 
upholding the charge that a journalist had been subjected to unlawful persecution by another 
person.  Its  reasoning  refers  to  the  challenges  faced  by  journalists  in  the  modern  society, 
including  through  online  harassment,  relying  on  the  case-law  of  the  European  Court  of 
Human Rights and international recommendations related to the protection of journalists161. 
The case has been widely regarded as a positive development for the protection of journalists 
in Finland162. 

The Government and law enforcement authorities are addressing further challenges to 
the safety of journalists. Preparatory work on other initiatives addressing the harassment of 
journalists  online  mentioned  in  the  2021  Rule  of  Law  report  is  still  ongoing163.  Since  the 
previous Rule of Law report, two new alerts have been published for Finland in the Council 
of Europe’s platform to promote the protection of journalism and safety of journalists164. The 
first  one  concerns  criminal  charges  brought  against  three  journalists  for  allegedly  revealing 
and intending to  reveal  state secrets  in  their reporting. The  case and its implications on the 
limits  of  freedom  of  expression  have  been  widely  discussed  in  public165.  The  second  alert 
concerns harassment of media workers during a protest held in Helsinki in February 2022166. 
The Finnish police has sought to prevent similar incidents by entering into a discussion with 
all  the  major  media  on  security  during  demonstrations,  issuing  recommendations  ahead  of 
major demonstrations and maintaining a helpline for media167. 

156  2022 Media Pluralism Monitor, country report for Finland, p. 10. 
157  2021 Rule of Law report, Country Chapter on the rule of law situation in Finland, p. 11. 
158  Act 698/2021 amending Chapter 25, Section 9 of the Criminal Code.  
159  Contribution from the Council for Mass Media for the 2022 Rule of Law Report. 
160  Supreme Court, judgment of 18 February 2022, R2020/680, ECLI:FI:KKO:2022:8.  
161  Ibid. 
162  Yle  (2022)  ’Johan  Bäckman's  stalking  conviction  provides  the  means  to  intervene  in  targeting,  says 

Professor – Head of the Journalists' Association: Jessikka Aro could not be silenced’.  

163  Addressing hate speech directed towards female journalists and strengthening restraining orders as referred 

to   in the 2021 Rule of Law report, Country Chapter on the rule of law situation in Finland, p. 11. 
164  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Finland. 
165  Committee  to  Protect  Journalists  (2021)  Finland  charges  3  investigative  journalists  with  revealing  state 
secrets;  Input  from  Human  Rights  Centre  the  2022  Rule  of  Law  Report,  Finnish  Union  of  Journalists; 
Information received from the Union of Finnish Journalists and the Council for Mass Media in Finland in the 
context of the 2022 country visit to Finland. 

166  At  least  five  Finnish  journalists  and  media  workers  were  attacked  during  a  ‘convoy’  protest  held  on  4 
February 2022 against restrictions to mitigate the COVID-19 pandemic and the increase in energy prices. 

167  Information received from the Finnish police in the context of the country visit. 

15 

 
                                                 
IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Finland  is  a  unicameral,  parliamentary  democracy,  in  which  legislative  proposals  may 
emanate  from  the  Government  or  Parliament  (although  in  practice  most  laws  are  based  on 
Government  proposals).  In  the  absence  of  a  Constitutional  Court,  ex  ante  constitutionality 
review is carried out by the Chancellor of Justice, who is attached to the Government, and the 
Constitutional  Law  Committee,  a  parliamentary  committee168 
the 
constitutionality of proposals submitted to Parliament. Moreover, all courts can carry out  ex 
post  constitutionality  review  in  concrete  cases169.  The  Chancellor  of  Justice,  the  Human 
Rights  Centre  and  the  Parliamentary  Ombudsman  play  an  important  role  in  the  system  of 
checks and balances. 

that  assesses 

The  legislative  process  is  transparent  and  the  involvement  of  stakeholders  is 
meaningful,  but  not  systematic.  The  obligation  for  public  authorities  to  promote  public 
participation in decision-making is stipulated in the Constitution170. The right to information 
about  legislative processes is  further developed in the  Act on the Openness  of Government 
Activities171.  The  legislative  process  is  further  specified  in  several  guidelines  of  the 
Government172. Stakeholders may be involved in several stages of that process, with public 
consultations lasting at least six weeks (eight weeks for extensive projects)173. Stakeholders 
involved in the legislative initiatives of the Government assess that the legislative process is 
very transparent174. However, it was also reported that in practice some stakeholders do not 
have the resources to participate and their experiences are therefore not sufficiently taken into 
account175.  An  OECD  report  from  June  2021  on  civic  space  highlighted  that  the  efforts  by 
authorities to  enhance opportunities for meaningful  engagement is  commendable, but  noted 
that  non-governmental  actors  were  not  systematically  invited  to  participate176.  The 
Government is currently preparing a resolution on the Finnish democracy policy, which will 
also holistically address the participation of the civil society177. 

The implementation of the Action Plan on Better Regulation continues. The Action Plan 
on Better Regulation, adopted by the Government in August 2020 and described in the 2021 

168  The  committee  is  made  up  of  members  of  Parliament  and  regularly  hears  independent  experts  on 

constitutional law.  

169  According to Section 106 of the Constitution if in a case before a court, the application of an act would be in 

evident conflict with the Constitution, the court of law shall give primacy to the Constitution.  

http://helo.finlex.fi/, 

170  Art. 14 of the Constitution. 
171  Act No. 21.5.1999/621, Act on the Openness of Government Activities. 
172  The  Legislative  Drafting  Process  Guide,  http://lainvalmistelu.finlex.fi/en/,  Guidelines  on  Government 
Guidelines, 

Proposals, 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/76118/omju_2008_4.pdf?sequence=1, 
Consultation guidelines, http://kuulemisopas.finlex.fi/ohje/kuulemisohje/.  
173  The Legislative Drafting Process Guide, http://lainvalmistelu.finlex.fi/en/. 
174  Information received in the context of the country visit to Finland from the Finnish Bar Association, Finnish 
Media  Association,  Union  of  Finnish  Journalists,  Council  for  Mass  Media  in  Finland,  Transparency 
International  Finland,  National  Courts  Administration,  Supreme  Court,  National  Human  Rights  Centre, 
Demla, and Amnesty International. 

Assessment 

Impact 

175  Contribution from the Human Rights Center for the 2022 Rule of Law Report p. 19. 
176  OECD (2021), Civic Space Scan of Finland, p. 150. 
177  Public  consultation  of  the  resolution  is  to  be  opened  in  June  2022.  The  resolution  will  be  based  on  the 
findings  of  the  National  Democracy  Programme  2022,  https://oikeusministerio.fi/en/national-democracy-
programme-2025. Follow-up information received from the Finnish authorities. 

16 

 
                                                 
Rule of Law Report178, aims to further improve the quality and transparency of the legislative 
drafting process179. Several  planned projects,  such  as the development  of an internal  digital 
portal  to  collect  information  for  law  drafters,  has  been  finalised,  while  others,  such  as 
preparation of new guidelines for impact assessment180, are still ongoing181.  

On  1  January  2022,  Finland  had  nine  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation182.  At  that  time,  Finland’s  rate  of  leading 
judgments  from  the  past  10  years  that  remained  pending  was  at  60%  and  the  average  time 
that  the  judgments  had  been  pending  implementation  was  11  years  and  11  months183.  The 
oldest  leading  judgment,  pending  implementation  for  17  years,  concerns  the  protection  of 
private and family life in relation to the lack of proper safeguards for the implementation of 
search  and  seizure  measures184.  On  1  July  2022,  the  number  of  leading  judgments  pending 
implementation remains nine185. 

The  Government  started  preparing  a  reform  of  the  Emergency  Powers  Act  following 
calls  for  a  review.  As  noted  in  the  2021  Rule  of  Law  Report186,  the  majority  of  measures 
enacted  to  address  the  COVID-19  pandemic  were  based  on  temporary  amendments  of 
ordinary legislation, usually the Communicable Disease Act, while emergency powers under 
the state of emergency187 were used to a lesser  extent.  Neither the  Emergency  Powers  Act, 
nor the Communicable Disease Act, were perceived to be sufficiently fit for the pandemic188. 
The  Emergency  Powers  Act  provides  primarily  for  military  crises  and  serious  economic 
disruptions189.  The  Communicable  Disease  Act  does  not  take  into  account  situations  where 
the capacity of the healthcare system is threatened and powers designed to prevent the spread 
of  a  disease  are  focused  on  public  activities190.  Several  bodies,  including  the  Chancellor  of 
Justice and the Constitutional Law Committee, called for a reform of the acts191. In December 

178  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 13. The Action Plan is 
composed of four main areas: legislative planning and drafting skills, interaction and communication, impact 
assessment, and utilisation of technology and digitalisation. 

179 Contribution from the Ministry of Justice for the 2022 Rule of Law Report. 
180  Input from Finland for the 2022 Rule of Law Report, p. 34. 
181  Information received in the context of the country visit to Finland from the Ministry of Justice. 
182  The adoption of necessary execution  measures  for a  judgment by the European  Court of Human  Rights is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

183  All figures are calculated by the  European Implementation Network and are based on the number of cases 
that  are  considered  pending  at  the  annual  cut-off  date  of  1  January  2022.  See  the  Contribution  from  the 
European Implementation Network for the 2022 Rule of Law Report, p. 40. 

184  Judgment  of  the  European  Court  of  Human  Rights  of  27  September  2005,  Petri  Sallinen  and  Others  v. 

Finland, 50882/99, pending implementation since 2005.  

185 Data according to the online database of the Council of Europe (HUDOC). 
186  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, pp. 12-13. 
187  The last state of emergency ended on 27 April 2021 and this state has not been declared since.  Input from 
Finland for the 2022 Rule of Law Report, p. 38; Information received in the context of the country visit to 
Finland from the Ministry of Justice. 

188  Contribution from the Chancellor of Justice for the 2022 Rule of Law Report p. 10. 
189  Contribution from the Chancellor of Justice for the 2022 Rule of Law Report p. 10. 
190  Contribution from the Chancellor of Justice for the 2022 Rule of Law Report p. 11. 
191  Contribution from the Chancellor of Justice for the 2022 Rule of Law Report pp. 9-10; Information received 
in the context of the country visit to Finland from the Ministry of Justice; 2021 Rule of Law Report, Country 
Chapter on the rule of law situation in Finland, pp. 13. 

17 

 
                                                 
 
2021, the Government decided to launch a comprehensive reform of the Emergency Powers 
Act192  and  appointed  a  working  group193  for  this  purpose.  The  Government  also  intends  to 
conduct a reform of the Communicable Diseases Act. The legislative schedule for this project 
has not been specified so far194. 

A law aiming to clarify the division of powers between the Chancellor of Justice and the 
Parliamentary  Ombudsperson  has  been  adopted  by  the  Parliament195.  In  2018,  the 
Government initiated a project to reduce overlaps in the tasks of the two supreme guardians 
of legality in Finland, the Chancellor of Justice and the Parliamentary Ombudsman. A draft 
law, which aims to clarify the division of tasks between the two institutions196 was submitted 
to the Parliament on 21 October 2021197, and adopted on 19 April 2022198. The Chancellor of 
Justice and the Parliamentary Ombudsperson continue to support the reform199.  

the  Parliamentary  Ombudsman, 

the  Human  Rights  Centre  and 

The Government proposed to establish a new agency to provide administrative support 
to  independent  bodies.  Beside  the  A  status  accredited  National  Human  Rights  Institution, 
its 
constituted  by 
Delegation200, Finland has  several  other specialised ombudspersons201  and other institutions 
tasked  with  protection  of  fundamental  rights.  As  many  of  these  institutions  have  a  small 
number of employees, some of the tasks related to their administration and resources202 are 
currently performed by the Ministry of Justice203. The Government has prepared a draft act to 
establish  a  new  Special  Authority  Agency  of  the  Judicial  Administration  to  take  over  the 
provision  of  support  for  these  authorities204.  The  competences  of  the  bodies  would  not  be 
changed205.  The  draft  act  is  intended  to  be  submitted  to  the  Parliament  in  2023206. 
Furthermore,  the  Human  Rights  Centre  has  prepared  a  proposal  on  strengthening  the 
cooperation of fundamental and human rights structures, based on the Centre’s study showing 
that  the  structures  are  fragmented  and  with  partially  overlapping  tasks,  which  can  create 
confusion for their users207. Apart from fragmentation, the Human Rights Centre reported on 
concerns about a lack of resources208. 

192  Input from Finland for the 2022 Rule of Law Report, p. 36. 
193  Information received in the context of the country visit to Finland from the Ministry of Justice. 
194  Written information received from the Finnish Government in the context of the country visit to Finland.  
195  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 14. 
196  The draft law does not change the mandates of the institutions.  
197  Input from Finland for the 2022 Rule of Law Report, p. 39. 
198  The law will enter into force on 1 October 2022. 
199  Contribution  from  the  Chancellor  of  Justice  for  the  2022 Rule  of  Law  Report  p.  1;  cf.  2021  Rule  of  Law 

Report, Country Chapter on the rule of law situation in Finland, p. 14. 

200  2020 Rule of Law Report, Country Chapter on the rule of law situation in Finland, p. 13. 
201  The  bankruptcy  Ombudsperson,  the  Ombudsperson  for  children,  the  Equality  Ombudsperson,  the 
Intelligence Ombudsperson, the Data Protection Ombudsperson, the Ombudsperson for older people and the 
non-discrimination Ombudsperson. 

202  Tasks related to accounting, human resources and financial administration. 
203  Information received in the context of the country visit to Finland from the Ministry of Justice. 
204  Apart from the seven Ombudspersons, the Authority would support also the  Safety investigation Authority, 
the licensed Attorneys Board, the Consumer disputes Board and the European Institute for crime Prevention 
and control. 

205  Information received in the context of the  country visit to  Finland from  the Human  Rights  Centre and the 

Ministry of Justice. 

206  Information received in the context of the country visit to Finland from the Ministry of Justice. 
207  Information received in the context of the country visit to Finland from the Human Rights Centre. 
208  Information received in the context of the country visit to Finland from the Human Rights Centre. 

18 

 
                                                 
The Government has initiated projects to improve the model of funding of civil society 
organisations.  The  civil  society  space  in  Finland  is  considered  to  be  open209.  The  two 
principal  sources  of  state  organised  funding  for  civil  society  organisations  in  Finland  are 
proceeds from gambling210 and public funding from the Ministries211. The funding from the 
proceeds of  gambling is  granted on a  yearly basis,  but  this  does not  allow them to  develop 
long term plans212. The funding from Ministries is fragmented and lacks a centralised system 
for applications and systematic evaluation213. A 2021 report from the OECD on civic space 
recommends adopting a more transparent and comprehensive approach to funding214, and to 
develop a holistic strategy to support civil society organisations in the long term, while also 
protecting  their  autonomy215.  In  response  to  the  OECD  report,  the  Minister  of  Local 
Government  appointed  a  working  group  to  explore  the  possibilities  of  implementing  the 
recommendations.  The  working  group  provided  its  input  in  October  2021216,  which  is  now 
being  considered  by  relevant  Ministries.  A  project  led  by  the  Ministry  of  Finance  to  create 
uniform,  digitalised  government  grant  processes  is  ongoing217.  The  Government  also 
launched  a  project  for  the  preparation  of  a  proposal  for  a  new  model  of  funding  from 
proceeds  from  gambling,  with  the  aim  to  give  civil  society  organisations  a  stable  and 
sufficient  funding218,  which  was  finalized  in  February  2022219.  A  new  Advisory  Board  on 
Civil  Society Policy, a  platform  for  the promotion of interaction between public authorities 
and civil society, was appointed by the Government on 27 January 2022220, after the term of 
office of the previous Board ended in February 2021221. 

The  authorities  have  launched  several  initiatives  to  promote  the  rule  of  law  in  public 
debate. In November 2021, the Minister of Justice organised a high-level seminar to discuss 
the state of the rule of law in Finland and the independence of the Finnish judicial system on 
the basis of the 2021 Rule of Law Report222. The Ministry of Justice contemplates to turn the 
seminar into a yearly event223. A research community Helsinki Rule of Law Forum has been 
established,  funded  by  the  Government  and  organised  by  the  University  of  Helsinki224.  

209  Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed 

and closed. 

210  The  Lotteries  Act  grants  the  exclusive  right  to  provide  gambling  services  in  Finland  to  a  state  agency 
Veikkaus,  and  stipulates  that  its  proceeds  shall  be  used  for  listed  public  purposes.  Act  No,  1047/2001  on 
Lotteries. 

211  OECD (2021), Civic Space Scan of Finland, p. 112; Information received in the context of the country visit 

to Finland. 

212  OECD (2021), Civic Space Scan of Finland, p. 111. 
213  OECD (2021), Civic Space Scan of Finland, pp. 111, 113.  
214  OECD (2021), Civic Space Scan of Finland, pp. 171-172.  
215  OECD  (2021),  Civic  Space  Scan  of  Finland,  p.  173.  See  also  Franet  (2022),  Country  research  -  Legal 
environment and space of civil society organisations in supporting fundamental rights - Finland, part 3.1. 

216  Input from Finland for the 2022 Rule of Law Report, p. 43. 
217  Input  from  Finland  for  the  2022  Rule  of  Law  Report,  p.  43  -  44.  For  information  about  the  project  see 

https://vm.fi/en/improving-the-administration-of-discretionary-government-grants. 

218  Input from Finland for the 2022 Rule of Law Report, p. 43. 
219  Written information received from the Finnish Government in the context of the country visit to Finland.  
220  Input  from  Finland  for  the  2022  Rule  of  Law  Report,  p.  43;  information  received  in  the  context  of  the 

country visit to Finland from the Ministry of Justice. 

221  2021 Rule of Law Report, Country Chapter on the rule of law situation in Finland, pp. 13-14. 
222  Information received in the context of the country visit to Finland from the Ministry of Justice. 
223  Information received in the context of the country visit to Finland from the Ministry of Justice. 
224  Helsinki  Rule  of  Law  Forum,  Analysing 

the  Rule  of  Law 

in 

the  European  Union, 

https://www2.helsinki.fi/en/researchgroups/helsinki-rule-of-law-forum.  

19 

 
                                                 
Among others, the Forum has published a study on the Rule of Law in the European Union 
and Finland225 in May 2022. 

225  Raitio Juha, Rosas Allan, Pohjankoski Pekka (2022), The rule of law in the European Union and Finland. 

20 

 
 
                                                 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2022 Rule of Law report 
can  be  found  at  https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-
consultation_en.   

Amnesty  International  Finland  (2022),  Contribution  from  Amnesty  International  Finland  in  the 
context of the country visit. 

Centre  for  Media  Pluralism  and  Media  Freedom  (2022),  Media  pluralism  monitor  2022  –  country 
report on Finland. 

CEPEJ (2021), Study on the functioning of the judicial systems in the EU Member States. 

Civicus, Monitor tracking civic space – Finland https://monitor.civicus.org/country/finland/. 

Chancellor  of  Justice  (2021),  Press  release,  Improving  the  transparency  of  decision-making  in  the 
management  of  the  coronavirus  epidemic  (Koronavirusepidemian  hoitoa  koskevassa  päätöksenteon 
avoimuudessa  parannettavaa)  https://www.okv.fi/fi/tiedotteet-ja-puheenvuorot/565/oikeuskansleri-
tuomas-poysti-koronavirusepidemian-hoitoa-koskevassa-paatoksenteon-avoimuudessa-
parannettavaa/.  

Chancellor of Justice, website: https://www.okv.fi/en/. 

in  decision-making  regarding 

Chancellor  of  Justice  (2022),  Press  statement,  Chancellor  of  Justice  Tuomas  Pöysti:  Improving 
transparency 
the  coronavirus  epidemic 
(Oikeuskansleri  Tuomas  Pöysti:  Koronavirusepidemian  hoitoa  koskevassa  päätöksenteon 
avoimuudessa 
https://oikeuskansleri.fi/-/oikeuskansleri-tuomas-poysti-
koronavirusepidemian-hoitoa-koskevassa-paatoksenteon-avoimuudessa-parannettavaa.  

the  management  of 

parannettavaa) 

Chancellor of Justice (2022),  Contribution from the Chancellor of Justice for the 2022 Rule of Law 
Report. 

Chancellor of Justice (2022), Contribution from the Chancellor of Justice in the context of the country 
visit. 

Committee to Protect Journalists (2021),  ‘Finland charges 3 investigative journalists with revealing 
state  secrets’  https://cpj.org/2021/11/finland-charges-3-investigative-journalists-with-revealing-state-
secrets/.  

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 
Finland https://fom.coe.int/en/alerte?years=2022&typeData=1&time=1654025528007.  

Demla (2022), Contribution from Demla for the 2022 Rule of Law Report. 

Directorate-General  for  Communication  (2019),  Flash  Eurobarometer  482:  businesses’  attitudes 
towards corruption in the EU. 

Directorate-General for Communication (2020), Special Eurobarometer 502: corruption. 

Directorate-General  for  Communication  (2022),  Flash  Eurobarometer  507:  businesses’  attitudes 
towards corruption in the EU. 

Directorate-General for Communication (2022), Special Eurobarometer 523: corruption. 

European  Association  of  Judges  (2022),  Contribution  from  the  European  Association  of  Judges  for 
the 2022 Rule of Law Report. 

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Finland. 

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Finland. 

European Commission (2022), EU Justice Scoreboard. 

21 

 
European  Court  of  Human  Rights,  judgment  of  27  September  2005,  Petri  Sallinen  and  Others  v. 
Finland, 50882/99. 

European Implementation Network (2022), Contribution from the European Implementation Network 
for the 2022 Rule of Law Report. 

Franet,  Institute  for  Human  Rights,  Åbo  Akademi  University  (2022),  Country  research  -  Legal 
environment  and  space  of  civil  society  organisations  in  supporting  fundamental  rights  –  Finland, 
Vienna,  EU  Agency  for  Fundamental  Rights    https://fra.europa.eu/en/publication/2022/civic-space-
2022-update#country-related.  

Financial Intelligence Unit, website: https://poliisi.fi/en/money-laundering. 

Finnish  Association  of  Judges  (2022),  Contribution  from  the  Finnish  Association  of  Judges  in  the 
context of the country visit. 

Finnish Bar Association (2022), Contribution from the Finnish Bar Association for the 2022 Rule of 
Law Report. 

Finnish  Council  for  Mass Media  (2021),  Number  of  complaints  rose  and  processing  accelerated  in 
2021’ https://www.jsn.fi/uutiset/kanteluiden-maara-nousi-ja-kasittely-nopeutui-vuonna-2021/.  

Finnish Council for Mass Media (2022), Contribution from the Finnish Council for Mass Media for 
the 2022 Rule of Law Report. 

Finnish  Government  (2021),  Code  of  conduct  for  officials.  (Virkamieseettinen  toimintaohje) 
https://julkaisut.valtioneuvosto.fi/handle/10024/163089.  

Finnish Government (2016), Guidelines for the consultation of legislative drafting (Säädösvalmistelun 
kuulemisohje) http://kuulemisopas.finlex.fi/ohje/kuulemisohje/.  

Finnish  Government  (2021),  Proposal  to  Parliament  for  a  law  amending  the  Act  on  Civil  Servants 
(Hallituksen 
muuttamisesta) 
https://www.eduskunta.fi/FI/vaski/HallituksenEsitys/Sivut/HE_187+2021.aspx, 
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasia/Sivut/HE_187+2021.aspx.  

virkamieslain 

eduskunnalle 

valtion 

esitys 

laiksi 

Finnish  Government  (2022),  Report  on  corruption  in  international  business:  Current  state  of 
regulation, application and training and need for change (Lahjonta kansainvälisessä liiketoiminnassa: 
Sääntelyn, 
muutostarpeet) 
https://julkaisut.valtioneuvosto.fi/handle/10024/163811.  

soveltamiskäytännön 

koulutuksen 

nykytila 

ja 

ja 

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2021-2023 
https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/163398/VN_2021_68.pdf?sequence=1&isA
llowed=y.  

Finnish Government (2022), Input from Finland for the 2022 Rule of Law Report. 

Finnish Government (2022), Written contribution from the Finnish Government in the context of the 
country visit. 

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districts.  

Finnish Parliamentary Ombudsman, website: https://www.oikeusasiamies.fi/en. 

GRECO  (2020),  Fifth  Evaluation  Round  –  Evaluation  Report  on  Finland  on  preventing  corruption 
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agencies. 

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coronavirus  coordination  group  violated  the  law’  (‘Valtio­neuvoston  kanslian  päätös  salata 
korona koordinaatio ryhmän 
https://www.hs.fi/politiikka/art-
rikkoi 
2000008608931.html.  

asiakirjoja 

lakia’) 

22 

 
the  Rule  of  Law 
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_CH_1.pdf?sequence=1.  

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(2017), 

fragile 

Eerik 

the 

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(Tekninen 
Whistleblower-kanaville) 
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ratkaisu 

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laatimisohjeet) http://helo.finlex.fi/.  

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response-22-october.pdf.  

to 

Supreme  Administrative  Court,  judgment  of  26  February  2021,  5198/1/19,  KHO:2021:26, 
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23 

 
Supreme  Administrative  Court,  judgment  of  1  December  2021,  20208/2021,  KHO:2021:170, 
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Bäckmanin vainoamistuomio antaa eväät puuttua maalittamiseen, sanoo professori – Journalistiliiton 
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24 

 
 
Annex II: Country visit to Finland 

The Commission services held virtual meetings in March 2022 with: 

  Amnesty International Finland 
  Anti-corruption Cooperation Network 
  Chancellor of Justice 
  Council for Mass Media in Finland 
  Demla 
  Financial Intelligence Unit 
  Finnish Association of Judges 
  Finnish Bar Association 
  Finnish Media Association  
  Helsinki Police Department  
  Human Rights Centre 
  Ministry of Economic Affairs and Employment 
  Ministry of Finance 
  Ministry of the Interior 
  Ministry of Justice  
  Ministry of Transport and Communications 
  Ministry of Social Affairs and Health 
  National Audiovisual Institute 
  National Bureau of Investigation  
  National Courts Administration  
  National Prosecution Authority 
  Parliamentary Ombudsman 
  Police of Finland 
  Prime Minister’s Office 
  Supreme Administrative Court 
  Supreme Court 
  Traficom  
  Transparency International Finland  
  Union of Finnish Journalists  
  Yleisradio Oy 

* The Commission also met the following organisations in a number of horizontal meetings:  

  Amnesty International  
  Article 19  
  Civil Liberties Union for Europe 
  Civil Society Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum 
  European Federation of Journalists  
  European Partnership for Democracy 
  European Youth Forum 
  Free Press Unlimited 
  Human Rights Watch  
 

ILGA Europe 

25 

 
 
International Federation for Human Rights (FIDH) 
International Press Institute 

 
 
  Open Society European Policy Institute ( OSEPI) 
  Osservatorio Balcani e Caucaso Transeuropa  
  Philea 
  Reporters Without Borders 
  Transparency International Europe 

26